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Høringssvar 2010

Dansk høring af EU's kriterier for offentlige grønne indkøb MST-147-00093

Danish consultation of EU criteria for green public purchasing

Organisation Det Økologiske Råd

1. Criteria set Catering & Food

Contact person  Jeppe Juul

The organic percentage

We propose to include indications for percentages for organic purchase throughout the criteria-document. Danish experience shows, that 60 % organic purchase is possible without raising the total costs (combined with changed practices and change to a healthier diet).

Of course the percentage could initially be set to be lower than 60%, or be higher if target is a more specific defined product group, but we think that it is important that it's indicated explicit that 60% could be a realistic target.

Aquaculture and marine products

It is important that the MSC-label is mentioned in the text as an example of a sustainable label for marine products. Even though it could be improved, it’s on the market and the best easy guideline in this field.

We recommend

  1. That the percentage for buying organic food is either set to 60 % (total) throughout the paper, or that an “E.g. 60%” is added in the help-text to indicate a realistic but still ambitious target.
  2. That the MSC-label is explicit mentioned as an example (p.5 award criteria 3 and p.11 criteria 3)

2. Criteria set: Construction

Contact person: Søren Dyck-Madsen


First of all it is important that the Sheet is simple and relevant for use especially in those (many) member states that do not have a tradition for setting green criteria in Public Procurement. And at the same time the sheet should not be obstructive for the traditions of Green Public Procurement in other (few) member states.

Seen on the large perspective this sheet seems a little bit too complicated for the above mentioned use. It tries to take everything in, which is a very good intention, but it also means that a lot of national and local preconditions cannot directly be seen in the document.

It is an acceptable Sheet, but it is in many ways a little bit outdated compared to front running demands in Green Public Procurement in Denmark.

Specific comments:

1.    Exclusion of certain building materials and demand for sustainable building materials is fair, but not good enough. It must include the possibility of demanding not to use hazardous chemicals placed on the EU candidate/SVHC list according to the REACH or on national lists of unwanted chemicals.

2.    The use of the word “Encourage” should in many places be replaced by the word “Demand”.

3.    If the buildings energy system is flexible in the energy demand in order to use more energy, when a lot is available (e.g. wind) and to save energy, when there’s a scarcity of energy (e.g. wind still) this should be awarded.

4.    Good overall insulation without heat bridges should be awarded.

5.    Buildings, where no temperatures on the inside of the building envelope goes below e.g. 15 degrees Celsius with an outdoor temperature of 0 degrees Celsius and an indoor temperature of 20 degrees Celsius, should be awarded, since this would very much improve indoor climate and greatly reduce the risk of fungus and mould.

6.    The word architect as the person/firm that carries through a building project is old-fashioned and misleading. It is the group of designers of the building that should be called on, since the planning and construction of very low energy building requires a much more integrated planning process than before.

7.    A demand for CV’s for the staff that will carry out the planning process should be included, since the ability of firms/bidders to do so is very much dependant on the actual members of the staff that will be doing the actual job.

8.    “Avoiding mechanical systems” is mentioned under e.g. ventilation. This phrase must be taken out, since mechanical systems might be very much needed for obtaining the future “near zero energy buildings” mentioned in the recast of the EPBD. Mechanical systems are in a rapidly improvement phase, and can provide both excellent indoor climate and energy savings.

9.    In stead could be inserted some mentioning of the benefits of individual systems and demand driven ventilation which will improve the indoor living/working environment quality of the building together with reducing the overall energy demand.

10.    For the building process it is important to mention the need for demands for avoiding water getting into the building in construction and demands for efficient drying out of the building before closing the building. Unwanted water from the building process is the cause of many mould incidents in newly constructed buildings.

11.    The proposals for how to give points for specifications of the building cannot only be based on the minimum standards of the national building codes. Many public authorities will demand e.g. a final energy use in the building well below minimum standards – These low energy demands should be fulfilled by all bidders and points should then only be given for doing even better.

12.    The definition of the low energy standard or Passive House standard must not only be defined as the need for heat. In some countries there are standards for the buildings total use of energy (except the private use of energy) including electricity for installations and lightning and cooling etc.) The definition should therefore cover the total energy use in the building – and be comparable with the coming definition of “Near zero energy” that is mentioned in the recast of the EPBD.

13.    The demand for the use of local RES (l-VEK) is not appropriate everywhere. In countries with efficient district heating systems the rationale of bringing more RES in the district heating could be more economy efficient than doing that on every single building.

14.    The mentioning of a typical percentage of RES (l-VEK) of minimum 5 to 20 % is far too low since the use of a standard effective heat pump could easily bring this to around 60 %.

15.    Aiming at least 20 % under the existing national minimum regulation is also far too low for public buildings. But it fortunately do not exclude that some countries go much further than this.

16.    FSC (or PEFC) should be included for the use of tropical forests hard wood.

17.    The use of building materials could be based on renewable resources, which excludes the use of Copper and Zink and other scarce metals. We redommend an additional sentence for demand for materials with very low energy consumption in the excavation, refining and production of the building material.

18.    We do not see the need for the competition on the R-value. If a demand for U-values and indoor minimum temperatures are set, the use of insulation materials with lesser R-value will express it self in the architecture of the building.

19.    Demands for better fire protection standards than the national standards could be added.

20.    Dual flush toilets/WC’s should be equipped with a standard 4/ 2 litres flush instead of a 6 / 3 litres flush, which is an old standard.

21.    The use of rainwater and grey water should be demanded with great care. The risk of contamination of the drinking water system in the building is there, and without very strict regulation and control the risk is rather big. Besides this is in many countries a very expensive way of saving drinking water. Provisions that reduce the need for drinking water are normally much more cost-efficient.

22.    The part on contract performance clauses is rather unclear how this should be done, and at what cost.

23.    The transport demands of the building materials should rather be part of the overall energy use calculation of the building materials – in stead of specific mentioning a certain way of transporting..

24.    Blower door tests should be obligatory also where natural controlled ventilation is applied for the building, in order to secure the focus on heat demand reduction.

25.    As an outcome of the cost considerations it should be recommended to take into consideration that energy effective easy maintenance and replacement of components have an important impact on the buildings life time performance.


3. Criteria set: Electricity

Contact person: Søren Dyck-madsen

The Commission proposal for a definition of GPP for “Green electricity” is totally unacceptable and makes no sense.

The proposal will lead to misinformation of consumers and procurement officers, when they have to buy electricity claiming to be “green” based on simple Guaranties of Origin. If electricity providers market products based on the present proposal, they will probably risk prosecution according to European marketing law (DIR 2005/29/EC of 11 May 2005, Article 6).

Green electricity can be produced in the form of renewable sources, but you can not buy green electricity. In order to become greener the procurement entity must generate a real effect either by GHG reductions or by more renewable production capacity.

Guaranties of Origin only document that some electricity has been produced somewhere to the grid. At the customer’s connection to the grid, it is not possible to differentiate between renewable electricity and average energy mix electricity.

Electricity from large hydro and wind farms is produced anyway – also if nobody bought the Guaranties of Origin. Wind and large hydro do have very low marginal production costs and will be traded in the market way before coal fired electricity and even nuclear power. This means that the only effect one can “buy” is the bookkeeper’s advantage of adding “green” at the bottom line of the accounting, making all the other forms and consumers a little dirtier – in theory – because the Guaranty of Origin has been taken out of the accounting.

The supply of Green electricity produced in Denmark and Europe is far greater than the demand for Guaranties of Origin. This means that there is so little market for Guaranties of Origin that the value is zero. Thus, any extra price given for Guaranties of Origin is a simple donation to the electricity supplier, which may subsequently be used for any activity that the supplier wants, e.g. coal plant development.Buying Guaranties of Origin therefore has no positive climate effect at all.

In Denmark we have just completed a “Voluntary declaration for Electricity with a climate choice” – a co-operation between stakeholders from NGOs over authorities to industry, and the declaration is accepted by the Danish Electricity Traders organised within the “Danish Energy Association – Traders”.[1]

This declaration covers 3 categories of electricity products with various levels of climate effects.

3. First category is to compensate by annulling emission allowances.

This can be done in two different ways

3.1.  Either buying out EUAs from the EU Emission Trading scheme

3.2.  Or by investing in emission reducing projects outside the UNFCCC / KP mechanisms.

Comment: The EUA annulling is a problem at the moment since the amount of “hot air” in the EU is steadily growing and not dealt with by the Commission.

4. Second category is to make an extra payment for each bought kWh in order to finance investment in additional RES production capacity being able to produce the same amount RES as the electricity bought. The payments must be legally bound to development of renewables through a fond construction or the like.

Comment: This will increase early investments in renewables and thus help the country to comply with the 20 % RES In 2020 Directive

5. Third category is the buying of Guaranties of Origin.

Here we have three categories:

5.1.  Firstly and best – and the only one with a potential for generating a real effect for climate – is to buy out Guaranties of Origin from RES production not more than 2 years old. By doing so the available amount of Guaranties of Origin is rather limited and there will be a possibility that the demand for those Guaranties of Origin during the next few years will be larger than the supply of those Guaranties. Thereby a market price will create economic incentives for more RES production capacity.

5.2.  Secondly the same goes for Guaranties of Origin no more than ten years old. However, there is much less chance that a price higher than null will develop for these Guaranties.

5.3.  Thirdly and lastly the buying out of Guaranties of Origin with no age limit really has no effect at all. There are so many Guaranties of Origin available that there is no real value and no price for them, giving no incentives at all to more RES production capacity. The price is therefore very low because it only covers administration costs of the scheme, and overprice taken by electricity providers is considered a donation to the company, with no constraints on how the donation should be spent in the company.

The draft EU Green Public Procurement guide suggests only the category that for sure has no effect at all.

If electricity must be part of a Green Procurement Scheme, Guaranties of Origin should be omitted and focus be directed only to categories 1 and 2 above. However, also the special case where category 2 products have resulted in additional renewable plants being constructed and run, the Guaranties of Origin therefrom may be included as the category 3.1 case of less than two years old Guaranties.

4. Transport

Organisation Det Økologiske Råd
Contact person  Jeppe Juul
Criteria set Transport


P. 5 The fleet average for CO2-emmissions for passenger cars and light-duty vehicles

The criteria for CO2-emission/km is set to high, when we are talking about the average for new cars. In comparison with EU-targets as such in this area, the ambitions should be higher to secure being a little in front of the general market.


The fleet average for new cars should not exceed 110 g CO2/km

The fleet average for new vans should not exceed 160 g CO2/km

P. 8 Vehicle tyres

Compared to the existing criterias for Rolling Resistance in the Nordic Swan and the German Blaue Engel, the proposed criterias for rolling resistance seems too weak. Compared to the coming energy labelling of tyres, these criteria will recommend tyres in a suboptimal placing on the A-G scale.


The rolling resistance should be set to 1,0 – 0,9  and 0,8

5. Textiles

Organisation Det Økologiske Råd
Contact person  Jeppe Juul
Criteria set Textiles

P. 6 (3.1)

PVC should be included in the list in 3.1, because of the used softeners and the problems it causes in the waste management system.



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